Protecting Residents, Protecting Patients: AMSA’s Response to Proposed ACGME Work-Hour Changes

The American Medical Student Association (AMSA) strongly urges careful reconsideration of the provisions of the Accreditation Council for Graduate Medical Education (ACGME) proposed major revision of the Common Program Requirements that would eliminate or weaken resident rest protections. Posted for public comment on September 8, 2026, with a proposed effective date of July 1, 2028, the revision would eliminate the 8-hour minimum rest period between shifts, cut post-call minimum rest from 14 to 12 hours, and drop the every-third-night cap on in-house call and the separate limits on night float [1–4].

AMSA shares the ACGME’s goal of reducing unnecessary administrative burden, and we welcome several provisions of this revision, including protected lactation time and a required program policy addressing the needs of pregnant residents [2]. However, work-hour limits are essential safeguards for resident well-being and patient safety. The current protections that are in place currently exist because rigorous evidence demonstrates that sleep-deprived residents are more prone to serious medical errors, sustain more needlestick injuries, motor vehicle crashes, and suffer higher rates of depression [5–8]. This evidence has not changed. Based on this evidence, scheduling flexibility for programs should not come at the expense of sleep deprived physicians-in-training who staff America’s teaching hospitals through the night.

As the voice of physicians-in-training, AMSA represents the voice of the medical students who will inherit these rules as the next generation of residents.

What the ACGME Is Proposing

In addition to the elimination of rest protections, the revision would remove Review Committees’ authority to set night-float and specialty-specific limits, while keeping the 80-hour weekly average, one day off per seven, and the 24-plus-4-hour shift cap [1–4]. The ACGME frames these changes as reducing burden on programs [2]. Public comment closes October 22, 2026 [3].

What the Evidence Shows

Two decades of research link extended wakefulness and inadequate recovery in residents to measurable harm to patients and to physicians themselves.

• Medical errors. In a randomized trial, interns working traditional extended shifts made 35.9 percent more serious medical errors and 5.6 times as many serious diagnostic errors as interns without extended shifts [5].
• Resident injury. After an extended shift, interns had 2.3 times the odds of a motor vehicle crash and 5.9 times the odds of a near-miss on the drive home [6].
• Mental health. An estimated 28.8 percent of resident physicians experience depression or depressive symptoms [8].

These findings shaped the Institute of Medicine’s call for protected sleep and minimum rest after every shift, including 14 hours off after extended duty [7].

Why the Remaining Limits Are Not Enough

• Averages protect the month; rest minimums protect the shift. The 80-hour cap is averaged over four weeks, so single weeks can exceed 100 hours [3].
• Twelve hours after a 28-hour shift is not sufficient for adequate time to commute home, eat, wash, rest, and recover before commuting back.
• Residents were underrepresented. They made up only 7.5 and 13.1 percent of the ACGME’s stakeholder survey respondents [3].

AMSA’s position aligns with the Institute of Medicine’s recommendations [7], AMA policy, and concerns already raised by the American Academy of Emergency Medicine and Committee of Interns and Residents (CIR/SEIU) [3, 4].

Call to Action: ACGME

AMSA urges the ACGME Common Program Requirements Task Force, Committee on Requirements, and Board of Directors to:

1. Retain at least 14 hours free after any 24-hour in-house clinical assignment.
2. Retain the 8-hour rest period between scheduled work periods, and make it a mandatory requirement rather than an expectation.
3. Retain the every-third-night limit on in-house call and the standard governing night float.
4. Require prospective evidence on resident safety and well-being before any rest protection is loosened.
5. Guarantee meaningful representation of residents, fellows, and medical students on the Task Force and in future stakeholder surveys.

Call to Action: AMSA Members

AMSA calls on every member, and every medical student and resident who will train under these rules, to act before public comment closes on October 22, 2026:

1. Read the proposal. Review the proposed Common Program Requirements and the ACGME’s rationale and impact statement, focusing on Section 6.
2. Submit a comment to the ACGME. Use the ACGME’s Review and Comment page. Name the requirements you oppose and describe how rest protections affect your safety, learning, and patients.
3. Use the CIR/SEIU commenting tool if it helps. The Committee of Interns and Residents (CIR/SEIU) built a browser add-on that helps residents draft and submit anonymous comments through the ACGME’s official survey [3].
4. Mobilize your chapter. Share this statement, host a comment-writing session, and urge classmates, residents, and faculty to submit a comment to the ACGME.

The last time protections were rolled back, students and residents answered. We must answer again, and we must do it now.

Resources & References

1. ACGME. Common Program Requirements (Residency): proposed major revision. September 8, 2026.
2. ACGME. Rationale and impact statement. September 2026.
3. Koh NJ, Alston MJ, Buser BR, Klingensmith ME, Malloy K. The ACGME Common Program Requirements major revision process: engaging the graduate medical education community. J Grad Med Educ. 2026;18(4):510-514. doi:10.4300/JGME-D-26-00719.1.
4. MedPage Today. Are resident work-hour protections being rolled back? September 2026.
5. Landrigan CP, et al. Effect of reducing interns’ work hours on serious medical errors in intensive care units. N Engl J Med. 2004;351(18):1838-1848.
6. Barger LK, et al. Extended work shifts and the risk of motor vehicle crashes among interns. N Engl J Med. 2005;352(2):125-134.
7. Institute of Medicine. Resident Duty Hours: Enhancing Sleep, Supervision, and Safety. National Academies Press; 2009.
8. Mata DA, et al. Prevalence of depression and depressive symptoms among resident physicians: a systematic review and meta-analysis. JAMA. 2015;314(22):2373-2383.